Drones are an amazing tool to increase efficiency and decreasing the time (and cost) for many tasks. &nbsp;The Federal Aviation Administration (FAA) unleashed commercial drone operations through 14 CFR §107, or “Part 107.” However, the FAA labeled Part 107 an “incremental” approach to beginning low-risk commercial drone operations in the national airspace.&nbsp; Due to its incremental approach, Part 107 is “silent” on many important topics, including operational safety, maintenance, and insurance. Regretfully, with these gaps, Part 107 is not a robust framework for effectively deploying large-scale, drone-as-a-tool programs.&nbsp; A prudent commercial drone operator should fill these Part 107 gaps with an operational handbook. This article provides a suggested framework, key topics, our experiences and some resources. &nbsp;The handbook should establish an aviation mindset&nbsp; Professional drone operations require a traditional aviation mindset. Drones present the next evolution in aerial technology. Because they follow the same laws of physics and fly in the same airspace as crewed aircraft, effective and safe drone use must be consistent with established aviation procedures.Establish an enterprise drone standard All Part 107 operations in an enterprise must follow a consistent set of standards. Our drone handbook standards apply equally to all drone pilots, aircraft, activities and our third party vendors. In practice, this means that our hundreds of drone pilots, spread across the US, all fully comply with the handbook.Maintain flight currency One striking gap in Part 107 is its “silence” on minimum flight experience. Specifically, Part 107 requires no initial practical flight evaluation, nor any previous flight experience to obtain a commercial remote pilot license. Further, a pilot is never obligated to fly after having been licensed.&nbsp; A pilot’s proficiency directly relates to the recency of their experience. Consequently, our handbook establishes an initial qualification process (IQP) for all pilots. This IQP is both an additional ground school after obtaining Part 107 licensure and a set of required minimum flight maneuvers. To maintain flight currency and keep aviator skills sharp, each remote pilot must fly at least once every 90 days. This improves pilot operational readiness and limits skill atrophy.&nbsp; Employ an enterprise Safety Management System (SMS) Part 107 does not require a safety management system (SMS). We recommend establishing one for enterprise drone operations. When developing your SMS, strike a balance between safety, training, and completing missions. Use a common sense approach to avoid “safety handcuffs” on remote pilots, and stifling operations. Alongside the SMS, we created a “high trust” culture among our drone professionals that encourages self-reporting of errors so all can learn and improve. Our pilots can use an online, automated safety reporting tool to report any issues during operations. The SMS outputs are used as anonymous examples in a quarterly safety meeting to proactively teach all pilots about potential operational pitfalls. Our SMS was developed from the International Business Aircraft Council (IBAC) protocols. Other standards for a drone SMS include the Drone Safety Team SMS guidance.Implement a system of record (SOR) for all drone operations We recommend implementing a common system-of-record (SOR) software platform that captures all flight data. A SOR should provide access to all critical flight information, including the flight start/end time, flight path, altitudes, weather and battery levels. Other key features include the creation of sortable lists of all personnel and aircraft, to verify pilot currency, drone documentation and track aircraft status. By allowing an organization to access and analyze relevant data, a SOR empowers operational safety oversight. Well-informed, data-driven decisions help evolve safety posture from reactive to proactive.Centrally set and track drone maintenance Maintenance tracking requires a common platform shared by all personnel to standardize recurring maintenance intervals. Our maintenance triggers meet or exceed the manufacturers’ guidance, are event based (on flight hours) and time based (on calendar months). For example, a drone must undergo a full inspection every 12 months. Our SOR tracks maintenance standards, providing insight to the accumulated drone hours, and current maintenance status. Using cloud based data, we can centrally “ground” a drone that does not meet current maintenance standards.Keep it short &amp; simple in handbook drafting Use the KISS principle in drafting: keep it short &amp; simple. Enterprise scale operations require addressing many topics in a meaningful handbook. Simplicity and brevity make your handbook more likely to be used by your pilots. We annually review our handbook to keep up with industry, regulations, technology and laws.Obtain aviation liability insurance While Part 107 does not mandate insurance, our handbook requires aviation liability insurance for all drones. Aviation liability insurance protects against personal injury or property damage from drone operations. &nbsp;We have a tiered coverage requirement. The larger the drone (including payload), the greater the insurance amount.Establish protocols for accidents, investigations &amp; reporting Certain drone accidents must be reported to the FAA and possibly the National Transportation Safety Board (NTSB). Your handbook should include a detailed checklist for the pilot to promptly capture all relevant accident details.&nbsp; To clarify when the FAA and/or the NTSB reporting rule are triggered, the handbook should also itemize an accident-reporting process and list of contacts. Harmonize drone operations with established corporate policies&nbsp; We recommend carefully adapting your existing corporate policies to align with your drone operations, ensuring they remain consistent with your overall drone program.Integrate privacy, cyber &amp; data protection into drone ops Integrate privacy advice into the handbook to ensure your drone operations comply with applicable privacy laws. Consider thoughtfully incorporating your corporate privacy policy into your drone handbook. If no corporate privacy policy exists, you can integrate some industry best practices, such as “Voluntary Best Practices for UAS Privacy, Transparency, and Accountability” by the National Telecommunications and Information Administration.&nbsp; Drone operators should consider a cybersecurity policy. Evaluate incorporating your corporate cyber policy into your handbook, or review other industry resources, such as the Cybersecurity and Infrastructure Security Agency (CISA) publication “Cybersecurity Best Practices For Operating Commercial Unmanned Aircraft Systems (UASs).”Finally, incorporate a data capture/use policy for any cameras or other recording devices on your drones. We require the camera, when inactive, be pointed in a horizontal or skyward direction to minimize the likelihood of inadvertent capture of protected data. We deliberately avoid capturing personal data that is not related to the mission.Don’t forget other corporate policies Align your safety and environmental policies with aviation practices (e.g., pilot safety vests, and drone battery disposal). Further, incorporate rules for interactions between drones and birds (including nests) to comply with federal and state avian laws.Establish a process to deconflict state / local law issues The FAA zealously protects drones use in the national airspace. Nonetheless, there are many state and local laws regulating drone usage. Many laws mix legitimate state police powers and an unfortunate overreach into drone operations in the national airspace. Your drone handbook should provide some guidance in navigating between FAA rules and state or local laws that impact drone operations. Preparing for beyond visual line of sight (BVLOS) operations, or Part 108 The time is ripe to implement a drone handbook. The 2024 FAA Reauthorization Act has directed the FAA to implement BVLOS rules, likely under “Part 108,” by early 2026. Implementing a drone handbook and standardizing your operating protocols now can increase your readiness for Part 108 operations.Conclusion A drone handbook is a tool to increase the proficiency and professionalism of your drone operations. It can help your organization safely unlock the full value of commercial drones. We welcome the opportunity to discuss any questions you may have. Contact us at VZdrones@Verizon.com. Happy flying!Authors:&nbsp; Dustin Schocken, Leader of Verizon&nbsp; Drone Use &amp; Compliance (VZDUC) at Verizon, Peter Vanderloo, Lead Lawyer at Verizon, Scott Forbes, Drone Safety &amp; Standards at VerizonCONTRIBUTION: The claims and statements made in this article belong exclusively to the author(s) and do not necessarily reflect the views of UAS Magazine or its advertisers. All questions pertaining to this article should be directed to the author(s).Printed in the 2024 issue of UAS Magazine/Directory

2024-09-18 - Up in the Air: Using an Aviation Mindset to Navigate the Gaps in Part 107 (UAS Magazine)

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Commercial Drone Operations for Enterprise Professionals

Up in the Air: Using an Aviation Mindset to Navigate the Gaps in Part 107

Up in the Air: Using an Aviation Mindset to Navigate the Gaps in Part 107

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